Privacy Policy

Draft — pending legal review

This is a working draft and is not production-ready legal text. It has been written to describe how Amana actually handles data, but it has not been reviewed or approved by a qualified solicitor.

Amana handles special category data under Article 9 of the UK GDPR, criminal offence data under Article 10, and identity documents. A policy covering that material must be reviewed by a data protection specialist before Amana is publicly available. That review has not yet taken place.

Do not rely on this document. It will be replaced with a reviewed version before launch.

Draft version 0.1 · Prepared July 2026 · Not in force — Amana is not yet publicly available.

1. Who we are

Amana is a matrimonial platform for Muslims seeking marriage, operating in the United Kingdom. For the purposes of the UK GDPR and the Data Protection Act 2018, the controller of your personal data is Digital Intentions Ltd, a company registered in England and Wales under company number 17402873, with its registered office at Office 1, Izabella House, 24-26 Regent Place, Birmingham, B1 3NJ.

Data protection enquiries: [privacy email — pending domain registration].

This policy covers the Amana mobile application and this website. It does not cover any third-party website we link to.

2. What we collect

Information you give us when you sign up

  • Your full real name. Amana does not offer aliases, usernames or display names, because verification badges are only meaningful attached to a checkable identity.
  • Your email address and a password, which we store only as a cryptographic hash and never in a readable form.
  • Your date of birth, used to confirm you are 18 or over and to display your age.
  • Your gender, sect, prayer level and profession.

Information you add to your profile

  • Location (a town or city, entered as text), ethnicity, height, education, languages spoken, marital status and a free-text "about me".
  • A profile photograph.
  • An optional voice or video introduction of up to 30 seconds.

If you use the "use my location" shortcut, your device determines an approximate position and converts it to a place name on your device. Only the resulting place name is sent to us. Amana never receives or stores your coordinates.

Verification data

  • Government-issued identity documents and a live facial image, submitted for identity verification.
  • The information required to obtain a DBS Basic Disclosure, and the result of that check.
  • Details of a UK degree submitted for confirmation with the awarding institution.
  • Documentary evidence of marital status where you declare that you are divorced or widowed.
  • Your answer to the UK residency question, and any supporting detail you provide.
  • The outcome and status of each check, and when it was completed.

Content you create in the app

  • Messages, voice notes and video notes you send to your matches.
  • Optional short notes ("compliments") sent when expressing interest.
  • Your expressions of interest and passes, your shortlist, and your matches.
  • Your private nikah checklist.
  • Reports you make about other members, and reports made about you.

Voice and video calls are transmitted directly between the two participants' devices wherever possible. We do not record calls, and no recording is created or stored.

Relationships and settings

  • Guardian relationships, where a guardian has created a profile — including the stated relationship, and whether the link has been ended.
  • Chaperone arrangements: who invited whom to read a conversation, whether it was accepted, declined or withdrawn, and when.
  • Any mosque you have chosen to associate your profile with, and whether you have separately chosen to be visible to that mosque.
  • Your privacy settings, including incognito mode.

Technical and account data

  • Notification tokens for your device, so we can alert you to new activity.
  • Your membership status, subscription dates, and any complimentary access granted.
  • Records of enforcement action taken on your account.
  • Server logs generated in the ordinary course of running the service.

We do not receive or store your payment card details. Subscriptions are processed by Google Play billing, and card information is held by Google, not by us.

3. Special category data

Some of what Amana collects is special category personal data under Article 9 of the UK GDPR — data that receives heightened legal protection because misuse of it can cause serious harm.

On Amana this includes:

  • Religious belief — your sect, and how you describe your prayer. These are religious or philosophical beliefs within the meaning of Article 9(1).
  • Racial or ethnic origin — your ethnicity.
  • Biometric data — the facial image used in identity verification, processed to confirm you are the person shown on your identity document. When used for that purpose it is biometric data for the purpose of uniquely identifying you, and falls squarely within Article 9.

We treat health data as out of scope: Amana does not ask about health or disability, and we ask that you do not include such information in free-text fields.

Our lawful basis for special category data

We rely on your explicit consent under Article 9(2)(a), alongside a lawful basis under Article 6 (see section 6).

What this means in practice:

  • Sect and prayer level are collected at signup and are visible to other members. They are fundamental to what Amana is for — a matrimonial platform for Muslims — and members expect to see them. By providing them you are giving explicit consent to their being processed and shown to other members.
  • Ethnicity is optional. You may leave it blank and still use every part of Amana. If you provide it, it is shown on your profile and can be used by other members as a search filter.
  • Biometric processing is separately and explicitly consented to on the consent screen shown before you begin identity verification. That screen tells you what is collected and what it is used for. Identity verification is entirely optional, and you can use Amana without completing it — though some features, including free access for female members and the visibility of a guardian-created profile, depend on it.

Consent can be withdrawn. You can clear your ethnicity at any time from your profile. You can delete your account at any time, which removes this data along with everything else. Withdrawal does not affect processing carried out before you withdrew.

Because sect and prayer level are collected at signup and used throughout the app, withdrawing consent for those specifically means deleting your account. We consider that honest rather than restrictive: an Amana profile without them would not function as a matrimonial profile.

4. Criminal offence data (DBS checks)

If you choose to complete a DBS Basic Disclosure through Amana, we process criminal offence data within the meaning of Article 10 of the UK GDPR, which may only be processed under the control of official authority or where authorised by law.

Specifically:

  • The DBS check is entirely optional. Amana is fully usable without it.
  • We rely on your explicit consent, and on the relevant condition for processing criminal offence data in Schedule 1 of the Data Protection Act 2018. [specific Schedule 1 condition — to be confirmed on legal review]
  • Other members never see the contents of your certificate. They see only whether the badge is verified, lapsed, or absent. The offence detail itself is never displayed to another member under any circumstances.
  • Details are shared with the provider who obtains the certificate, and with nobody else.
  • A Basic Disclosure covers unspent convictions and conditional cautions only. It is not an enhanced check.
  • The badge lapses three years after the certificate is issued, and can be renewed.

We maintain a record of our processing of criminal offence data as required by the Data Protection Act 2018. [appropriate policy document — to be prepared at legal review]

5. Identity and evidence documents

Identity documents, facial images, DBS information and marital status evidence are the most sensitive material Amana handles, and are treated differently from everything else:

  • They are never public. Every stored file can only be retrieved through an authenticated request that we check against the requester's identity. Nothing is on a public web address and no shareable link exists.
  • Marital status documents are visible only to you and to Amana staff reviewing them. No other member can ever retrieve one, matched or otherwise.
  • Other members see outcomes, never documents. A badge shows a status; it never exposes the underlying material.
  • They are deleted when you delete your account, including the stored files themselves and not merely the references to them.

6. Why we use your data, and our lawful bases

What we doLawful basis (Article 6)
Create and run your account; show your profile to other members; deliver messages, calls and matchesPerformance of a contract with you
Take subscription payments and manage membershipPerformance of a contract with you
Carry out verification checks you have requestedPerformance of a contract with you, plus explicit consent for the special category and criminal offence elements
Confirm your email addressPerformance of a contract with you
Keep the platform safe: moderation, investigating reports, enforcing our terms, and preventing fraud and abuseLegitimate interests — protecting members from harm and maintaining a trustworthy platform
Retain moderation records after an account is deletedLegitimate interests — preventing someone from evading enforcement by re-registering
Send notifications about activity on your accountPerformance of a contract with you
Show your ethnicity, sect and prayer level to other membersExplicit consent (Article 9(2)(a)), with performance of a contract under Article 6
Meet our legal obligations, and respond to lawful requestsLegal obligation

Where we rely on legitimate interests, we have considered whether our interest is overridden by your rights and freedoms, and we can provide our assessment on request.

7. Automated content checking

Text messages and profile photographs are automatically screened for abusive and harmful content by a third-party content moderation service.

Two points matter, and both are structural rather than promises:

  • The automated system can only create a report for a human moderator. It cannot suspend, restrict, hide or delete anything or anyone. Every enforcement decision on Amana is made by a person who has reviewed the actual content.
  • There is therefore no automated decision-making producing legal or similarly significant effects within the meaning of Article 22, because no decision about you is taken solely by automated means.

Voice notes, video notes and video introductions are not automatically screened, as the service we use analyses text and images only. Marital status documents are not automatically screened either, as they already go to a human reviewer.

8. The in-app support assistant

Amana includes an in-app Help & Support chat. When you send it a message, that message is processed by a third-party AI inference provider — Groq, Inc., based in the United States — to generate a reply. This is a new category of processing, disclosed here alongside the special category data (section 3), criminal offence data (section 4) and identity documents (section 5) described above.

  • What is sent, and what is not. The text of your support-chat message is sent to the provider to generate an answer. Before anything is sent, the message is checked to see whether it touches a sensitive or protected topic — for example your identity or DBS verification, a payment dispute, a safety or harassment report, account security, a data request, or anything suggesting a user may be under 18. If it does, no answer is generated by the AI at all: the message is routed to a member of our team instead, and you are simply told it has been flagged for a person to look into. Sensitive topics are handled by people, not by the AI.
  • Training and retention. Based on the provider's terms as we understand them, Groq does not use data submitted through its API to train or fine-tune its models, and does not retain inference requests by default. The provider may temporarily log request and response content for up to 30 days for the limited purposes of troubleshooting errors and investigating suspected abuse. [We are enabling the provider's zero-data-retention setting, which removes even that troubleshooting window; this clause will be updated to confirm it once that is in place. Until then, the 30-day window above applies.]
  • An honest limitation. The topic check above acts on what your message is about, not on whether you happen to type a sensitive value into it. If you paste, say, a document number into an otherwise ordinary question, that text is still sent to the provider. For that reason the chat carries a visible reminder not to share sensitive personal details there — please don't. Anything sensitive should go to a person, and the assistant will put you in touch with one.
  • It is not automated decision-making. The support assistant answers questions; it makes no decision about you that produces a legal or similarly significant effect, and every sensitive matter is handled by a person.

This is an international transfer of personal data to the United States; see section 11.

9. What other people can see

Because Amana is a social platform, some of your data is shown to others by design. In summary:

  • Other members see your name, age, location, profession, education, ethnicity, marital status, sect, prayer level, "about me", verification badge statuses, and whether your profile was created by a guardian. Your photograph is blurred until interest is mutual. Your voice or video introduction cannot be played until you have matched.
  • Your matches additionally see your unblurred photograph and can play your introduction.
  • A chaperone, if invited by one participant and accepted by the other, can read that single conversation and the participants' names. Nothing else.
  • A guardian can see everything on a profile they created, including all of its conversations in full.
  • A mosque you have associated with and separately made yourself visible to sees only your name and whether it has granted you community verification.
  • Nobody else sees your email address, your date of birth as such, your verification documents, your DBS certificate contents, your nikah checklist, your shortlist, your reports, your membership status, or your mosque association.

Turning on incognito removes you from other members' search results and daily batches.

10. Who we share data with

We do not sell your personal data, and we do not share it for advertising. We share it with the following categories of processor, each acting on our instructions:

WhoWhat they receive
Identity verification providerYour identity document images and facial image, to confirm the document is genuine and matches you
DBS check providerThe identifying details required to obtain a Basic Disclosure, and the resulting certificate
UK degree verification serviceThe degree details you submit, checked against the awarding institution's records
Hosting and database providerHosts the Amana service and stores its data
Object storage providerStores video content uploaded to the app
Email delivery providerYour email address and the verification code we send you
Google (Play billing and push notifications)Processes subscription payments; delivers notification alerts. Notification alerts contain only a generic prompt and a category — never message content, names or match details
Content moderation providerText messages and profile photographs, screened for harmful content
AI support-assistant provider (Groq, US-based)The text of your Help & Support chat messages, to generate a reply — except where a message touches a sensitive or protected topic, in which case it is routed to a person and nothing is sent to the AI. See section 8

[named providers and their data processing agreements — to be listed at legal review]

We may also disclose data where required by law, to a court or regulator, or to protect the vital interests of any person.

11. International transfers

Some of our processors operate outside the United Kingdom. Where personal data is transferred outside the UK, we rely on UK adequacy regulations, or on the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any additional safeguards required.

[per-processor transfer mechanisms — to be documented at legal review]

12. How long we keep things

  • Your account and profile — for as long as your account exists.
  • Verification documents and submissions — for as long as your account exists, then deleted.
  • Badge outcomes — retained while your account exists, with sensitive submission detail removed on deletion.
  • Messages — retained for as long as either participant's account exists, because a conversation is shared between two people.
  • Moderation records — retained after deletion, with identifying details stripped out, to prevent enforcement being evaded through re-registration.
  • Compliance records of data exports and deletion requests — retained as a record that we honoured the request.
  • Server logs — retained for a short operational period.

[specific retention periods — to be set at legal review]

13. Your rights, including export and deletion

Under UK data protection law you have the right to be informed; of access; to rectification; to erasure; to restrict processing; to data portability; to object; and rights relating to automated decision-making. You may also withdraw consent where we rely on it.

Export — built into the app

You do not have to make a request. In the "your data" section of your profile, tap export. Amana assembles everything it holds about you into a machine-readable file and hands it to your device's own save dialogue. It is immediate and there is no waiting period. This covers your right of access and your right to data portability.

Notably, this works regardless of whether your subscription is active. Your rights over your own data are not contingent on payment.

Deletion — built into the app

Also in the "your data" section, confirmed with your password. Deletion happens immediately and cannot be undone.

What is removed: your name, email address, date of birth, location, ethnicity, height, education, languages, "about me", photographs, voice and video recordings, identity and evidence documents, verification submission detail, your nikah checklist, your shortlist, your record of interest and passes, your notification tokens, and your notifications. Any live chaperone arrangements you are party to are withdrawn.

What is retained, and why:

  • Messages you sent remain visible to the person you sent them to, attributed to a deleted member. A conversation is shared property, and erasing one participant's copy would destroy the other's own record of a conversation they took part in. Any audio or video you sent is deleted, even where the message remains — a recording of your voice or face is exactly what an erasure covers, and there is no version of it that can properly be retained.
  • Moderation records are kept, with identifying details removed. Without this, deleting and re-registering would erase a record of harmful behaviour and leave the member who reported it with nothing.

We consider these to be justified restrictions on erasure — the first because it is necessary to protect the rights and freedoms of another person, the second because it is necessary for our legitimate interest in preventing harm on the platform. [to be confirmed at legal review]

Everything else

For rectification, restriction, objection, or any question about this policy, contact [privacy email — pending domain registration]. We respond within one month, as the law requires, and will tell you if we need longer.

14. Guardian-created profiles

Where a guardian creates a profile for someone else, both are individuals with rights under this policy. Some specifics:

  • The person the profile is for has the same rights over that profile's data as any member — including export and erasure.
  • A guardian can read every conversation on a profile they manage. This is inherent in how the feature works and is stated plainly on our guardian page. It is not a setting that can be turned off.
  • If a guardian deletes their own account, profiles they still manage are deleted with them, because such a profile has no independent login and would otherwise be unreachable personal data.
  • Both parties must be 18 or over.

If a profile has been created for you and you did not agree to it, contact us and we will help.

15. Security

We take appropriate technical and organisational measures, including: passwords stored only as cryptographic hashes; encrypted connections; authenticated access checks on every stored file; separate administrative systems with their own credentials; screenshot blocking on sensitive screens in the app; and rate limiting against automated attack.

An independent security assessment is planned before public launch. [assessment status — to be confirmed]

No system is perfectly secure. If we become aware of a breach likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office within 72 hours and, where the risk is high, notify you directly.

16. Age

Amana is strictly for adults aged 18 and over. We verify age at signup on our servers, not merely in the app, and we do not knowingly collect data from anyone under 18. If you believe an underage person has an account, contact us and we will remove it.

17. Changes to this policy

We will publish any updated policy on this page with a new version date. Where a change materially affects how we use your data, we will notify you in the app before it takes effect rather than relying on you checking this page.

18. Complaints

Please contact us first — most things are resolved quickly. You also have the right to complain to the UK's data protection regulator at any time:

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
ico.org.uk